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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

43) ll-B-18 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:53 AM Sheet 43 of 276 
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II-B-18 

NOTE: Parts of this item are not legible. 
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2T-B-/8 

MEMORANDUM 

SUBJECT: 

FROM: 

NOV 2 5 1986 :•.•'; inftl lllj., 

U ; | j ^ I ^ 1991 U 

* 1 1 

E5^S_52---S 

OH-ICF UIAIR ASI> RADIMION 

Interpretation of Reconstruction (40 CFR 60.15) 

Division 

TO: 

John B. Rasnic, Acting Dired 

Stationary Source Compliance 

Office of Air Quality Planning and Standards 

James T. Wilburn, Chief 

Air Compliance Branch 

This is in response to your September 12, 1986 memorandum 

requesting the Stationary Source Compliance Division's (SSCD's) 

opinion of the Florida Electric Power Coordinating Group's (FCG's) 

interpretation of the reconstruction regulation at 40 CFR 60.15. 

FCG is proposing specific guidance on the items to be included 

in the fixed capital cost of fossil-fuel-fired steam electric 

plants. 

Section 60.15 of the New Source Performance Standards (NSPS) 

specifies that reconstruction occurs if the fixed capital cost 

of the new components exceeds 50% of the fixed capital cost of 

a comparable entirely new facility, and if it is technologically 

and economically feasible for the facility to comply with the 

applicable NSPS. As cited in FCG's summary, the December 16, 

1975 preamble to the reconstruction regulations defines fixed 

capital cost as the capital needed to provide all the depreciable 

components, including the costs of engineering, purchase and 

installation of major process equipment, contractor fees, instrumentation, auxiliary facilities, buildings and structures. Costs 

associated with the purchase and installation of air pollution 

control equipment are only included in the fixed capital cost 

to the extent that the equipment is required as part of the 

manufacturing/operating process. When determining reconstruction costs, care should be exercised to include only those 

costs, associated with the reconstructed affected facility. 
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In making the final determination of whether the change in 

question constitutes reconstruction, the Administrator will 

consider all technical and economic limitations the facility 

may have in complying with NSPS. Points to be considered by 

the Administrator are listed at §60.15(f). 

FCG has proposed a list of specific items to be included 

in the reconstruction costs for fossil-fuel-fired steam electric 

generating units. The list is composed of the accounting categories provided in the Federal Energy Regulatory Commission 18 

CFR Part 101. SSCD and the Emission Standards and Engineering 

Division have reviewed this list and have determined that a 

substantial number of the items are not appropriate for inclusion in the cost analysis. Only the costs of items included 

in, and activities associated with, the affected facility are 

to be included in the reconstruction costs. The affected 

facility for fossil-fuel-fired steam electric plants consists 

only of the steam generating unit as defined at 40 CFR 60.40a 

and §60.41a. The affected facility is more specifically described 

at §60.41a in the proposed standards (Attachment A) , and in 

the July 1978 Background Information Document (Attachment B). 

Section 60.41a(a) of the proposed standards for electric 

utility steam generating units elaborates on the definition 

of steam generating unit: "... A steam generating unit includes 

the following systems: (1) Fuel combustion system (including 

bunker, coal pulverizer, crusher, stoker, and fuel burners, 

as applicable). (2) Combustion air system. (3) Steam generating system (firebox, boiler tubes, etc.). (4) Draft system 

(excluding the stack)." The affected facility then starts 

at the coal bunkers, and ends at the stack breeching. 

The units which constitute the affected facility may 

best be conveyed by the diagram in Attachment C. As the 

diagram indicates, the following items are included in the 

affected facility: boilers and equipment, breeching, draft 

equipment, lighting systems, oil-burning equipment, pulverized 

fuel equipment, stoker or equivalent feeding equipment, and 

pressure oil systems. The following equipment would only be 

included in reconstruction costs to the extent that they directly 

service the boiler: foundations and structural steel, buildings, 

ash handling equipment (generally only the discharge valves to 

the ash hopper), boiler feed water system, coal handling and 

storage equipment (only the coal bunker and pulverizer), instru-
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hTrvcH.-ut-.vT A 

TUESDAY, SEPTEMBER 19, 1978 

PART V 

ENVIRONMENTAL 

PROTECTION 

AGENCY 

ELEaRIC UTILITY STEAM 

GENERATING UNITS 

Proposed Standards of 

Performance and Announcement 

of Public Hearing on Proposed 

Standards 
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/iTTACH/Vlb/VT r\ 

42174 

Usee of alternative methods, enforcea-Urty. and improvementa in emission control technology. 

Executive Order 12044. dated March 

34. 197S, whose objective to to improve 

Government regt—_tfo_s, reyuifes executive branch agencies to prepare 

regulatory analyses' for regn—itions 

tint may have major economic consequence-. The proosed standards meet 

the criteria far-preparation of a regulatory analysis as outlined In the Executive order. Therefore, a regulatory 

analysis tuts been prepared as required. The analysis la contained in 

the harhgro.--i ___tn__-__-, documents for the proposed standards. The 

regulatory analysto to not being pob* 

Usbed as a separate docu-ieut because 

the work was begun before tbe Presldent's Executive order was published. 

However, in order to* present a better 

understanding of tbe analyses' conrtained In the background Information 

documents, a summary of the analyses 

is included In the preamble. The summary >*f«~-«gga in detail the aftera_r 

ffvng- nnr\o.iA*ry*A 

Section 317 of the dean Afar Act requires the Adn___Etratar to prepare an 

-tons deten-ined by the . 

to-be nihstairfh.1 The 

determined that the 

mens and ____ded the i 

in theb_cfegre*—_d 

Dated: September IL, 1878a. 

DOOU_-__. 

It to proposed that 49 CFR Part W 

be amended by revising the heading 

and {60.40 of Subpart O. by adding a 

new Subpart Da. by ______ a new reference mp-iorf to flpprnriiT A. and by 

reserving Appendix Baa follnwi. 

L The headins forP-lniM. E> la revised to read aa fo-mau 

40.40 ia SB-ended by 

.p_(aX3)asfbI]owK 

_«M» Apfiic-k-ir/ MMI 

f J)la not subject to the piovfeluus of 

Subpart Da. 

(Sec. III. 301'a) of the Oean Air Act aa 

amende* (42 UJB.C. 7111. 7_nca)« 

MAES 

Sec _ 

99.40s Appffcsbflrtr &nd cfesignstion of —ffected rac-tty. 

60.41a Definitions. 

60.42a Standard lor particulate matter. 

60.43a SUndantferautfurdfoxide. 

60.44a Standard for nitrogen oxides. 

09.45a Co—imer——1 demonstration permit. 

90.4o_ CaWmiaifti—ai- provisio—s. 

SS4Ta ItertBsfam monitoring. 

M.4-S Co-Lpnanee drtern-nation 

Bfeporting Kt)u_-_a__a. 

: See. 111. 

ao.4Sa 

Amauasii. See. 111. 301(a> oTthe Clean 

A_- __t*_s aroe-tted (49 DAC 74X1, 

MOlta)). and -__-r-_ . a-UMrity as noted 

below. 

mwLW^LWf D#*M5tQflA_VVI Or rvrfOflMHlCe fOf 

EPKtrlc tffltWy Staom wonoFVrwf (ftirts rev 

h Cammanw* Mat SayI* 1970 

ItadOky. 

far The affected facility to which 

this subpart, applies is each electric 

otfltty steam generating unit: 

CZ) Which. Is T-M - of rnmhimtfng 

•tore than'73 meg—watts (—50 m_lion 

Btu/hour) beat Input of _-__. fuel 

Cefther alone or in combination with 

any other fuelX and 

_U> For which construction or modir 

fi-a-toa ia conanrnced after September 18.1.78. 

(b) This subpart appUea to -teetrie 

sti-ty combined cycle gaa turbines 

that are capable o_ cnmrn_ttn« more 

than 73 _-M»i..u (360 mi-ten Btu/ 

hour) heafe input of loss- fuel in the 

steam generator. Only emissions resulting from comhustton of fossil fuel 

&_ the steam generator are subject to 

this subpart. (The gas turbine emisMD-Ject to Subpart GO.) 

X Anew Da is added aa icrt-

,C_41 _ 

JLs used in this subpart, all terms not 

defined herein shall have the meaning 

given them in the Act and to subpart 

A ox U—Spart. 

fa) "Steam generating' unit" means 

any ftimace, boiler, or other device 

used for combusting fuel for the purpose of producing steam (including 

fossil ftrel-fired steam generators associated with combined cycle gas turbines; nuclear steam generators are 

not Included). A steam generating unit 

tnrlui-. the following systema; 

(I) Fuel combu.si.ion system (Including bunker, coal pulverizer, crusher, 

stoker, and fuel burners, as applicable), 

t_> Combustion air system. 

<3> Steam generating system (firebox, boiler tubes, etc). 

(4) Draft system (excluding the 

(b) "Electric utflity steam generating 

unit" means any steam electric generating unit that is constructed for the 

purpose of supplying more than onethird of its maximum design electrical 

output capacity to an electrical distribution system for sale. Any steam distribution system that is constructed 

for the purpose of providing steam to 

a steam-electric generator that would 

produce electrical energy for sale is 

also considered tin determining the 

electrical energy output capacity of 

the affected facility. 

(c) "Fossil fuel" means natural gas, 

petroleum, coal, and any form of solid, 

-quid, or gaseous fuel derived from 

such material for the purpose of creating useful heat. 

(d) '"Subbituminous coal" means coal 

that is classified as subbituminous A. 

B, or C according to the American Society of Testing and Materials' 

(ASTM) Standard Specification for 

Oa-rifVatton of Coals by Rank D388-

00. 

(e) -lignite- means coal that to classified as lignite A or B according to 

the American Society of Testing and 

Materials* (ASTM) Standard Specification for Classification of Coals by 

Rank D3SS-00. 

(f) "Coal refuse" means waste products from coal mining, physical coal 

cleaning, and coal refining operations 

(e.g. calm, gob, or other rejects) containing coal, ashr matrix material, clay, 

and organic and inorganic material. 

(g) "Potential combustion concentration" means the theoretical emissions 

(ng/J, lb/millfon Btn) that would 

. result from comb—stion of a fuel in an 

u—Cleaned state (without emission control systems) and: 

(1 > For particulate matter —c 

(i) 3.000 ng/J heat input (7.0 Ib/mflHon Btu) for solid fuel; and 

(ID 75 ng/J heat input (0.1T Ib/tnilBon Btu) for liquid fuels. 

- (2) For sulfur dioxide Is determined 

trader 8 0O.48a(b). 

(3) For nitrogen oxides is: 

(1) 290 ng/J heat input (0.07 !_/___-

lion Btu) for gaseous fuels; 

(ti) 310 ng/J heat Input (0.73 lb/mflllon Btu) for liquid fuels, and 

(ill) 990 ng/J heat input (3.3 lb/million Btu) for solid fuels. 

U-> "O-nbtned cycle gas turbine" 

means s stationary gas tnr__se system 

where heat is recovered from the exhaust gases by passing the ernati-t 

gases through a steam generating unit, 

fossil fuel may also be combusted in 

the steam generating unit. 

(i) "Utility company" means the 

largest organization, bust-em, or governmental entity that owns the affected faculty (e.g. a holding company 

with operating subsidiary companies). 

<J) "System capacity** means the 

sum of the rated electrical output capacity of all electric generating etjutpVO- *X MO. MS—TK-DAT, SE \9, W7t 
P.7 

?r\ T-TV* . 

Environn:•„•;••:_I Protection 

Ager.cy 

Office of Air Quality 

Planning and Standards 

Research Triangle Park NC 2771 1 

Air 

•-ePA-45O/2-73-O05a 

July 1973 

ATTACH V*EUT"B 

Steam Generating 

Units 

.-g^---B2_. 

Background 

Information for 

Proposed NOx 

Emission Standards 
'•&?" 

MODIFICATION AND RECONSTRUCTION 

P.8 

5.1 GENERAL 

The terms modification and reconstruction have special meanings 

when used in new source performance standards. These terms are clarified 

in Subpart A, Part 60, Subchapter C, Chapter 1, Title 40, Code of 

Federal Regulations. In general terms, a modification is a selected 

type of change which increases the emission of selected pollutants to 

the atmosphere. When the alterations are limited, new source performance 

standards only require that increases in the emission of selected 

pollutants be prevented. In general terms, reconstruction is a change 

which is so substantial as to class the source as a new source rather 

than an altered existing source. In this case, the source becomes 

subject to all the limits of the new source performance standard. 

5.2 MODIFICATION 

5.2.1 Scope and Effect of Modiftation Regulations 

A modification means any change in the method of operation of an 

existing facility which increases the amount of any air pollutant (to 

which a standard applies) emitted into the atmosphere by that facility" 

or which results in the emission of any air ndllutant (to which a 

standard, applies) into the atmosphere not oreviousty"emitted. The term ^"^ 

modification is further limited by exempting selected types of changes 

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from the aDDlicability of new source Derformance standards. 

Normally, all that is required of an existing facility is that 

emissions of a specific pollutant after alteration be no more than they 

were before alteration. These modification regulations only apply to 

the pollutants of the new source standard and apply on a pollutant-bypollutant basis. In rare cases, emission of one or more pollutants may 

be less than the limit of a new source performance standard prior to 

the alteration. In this situation, an emission increase is allowed, up 

the limit of the applicable new source performance standard. Consequently, 

when changes are made which cause an existing source to become subject 

to a new source performance standard, emission control systems are 

normally altered to prevent emission increases. In exceptional circumstance 

no additional air pollution control equipment may be needed to prevent 

an emission increase or; limiting emissions to the level of the new 

source performance standard may be less costly than preventing an 

emission increase. 

Adding an affected facility to a plant or replacing an existing 

facility within a Dlant would not cause other unchanged existing facilities 

within the plant to become subject to the no emission increase rule. 

Where a plant has several existing facilities, the no emission increase 

rule may not apply to an altered existing facility if net plant emissions 

are not increased. For example, if emissions of pollutant A are increased 

by a change to facility 1 in a plant, this emission increase is allowed 

if emissions of pollutant A from facility 2 are decreased by an amount 

___£ua...rtp..or..-exceedinq.^.the ..amount of, jn.crease" from faci 1 ity'/T."""". . 
Emission increases are allowed if such increases are caused by 

routine maintenance, repair, and replacement. Emission increases are 

also allowed if caused by increases in production rate which can be 

accomplished without major capital expenditure. Increases in emissions 

caused by longer operating hours are also exempted from the rule on no 

emission increase. Another exemption is for the use of an alternative 

fuel or raw material if—prior to the date any standard becomes applicable— 

the existing facility was designed to accommodate that alternative use. 

Conversion to coal as stipulated in Section 111(a)(3) of the Clean Air 

Amendments of 1977 is not considered a modification. Emission increases 

caused by the addition or use of any system whose primary function is 

the reduction of air pollutants, are also exempt from the no emission 

increase rule. 

5.2.2 Modified Pulverized Coal-Fired Steam Generators 

For the purposes of determining if modification regulations apply 

or should apply, the pulverized coal-fired steam generator system is 

defined as including the following major components. 

a) pulverizer system 

b) combustion air system 

c) steam generation system 

d) draft system 

•_-zz-^) 'fuel

 :i^_irctit)TFsystem 

The major points which define the inlets to the affected facility 

are: ._._--,•_.•. - .-._._ .v. -.. ,-.,-.- .,_-,..-_,-,-• 

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i 

i\\\ 

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•fra 

ii; 

1. The inlet to the pumps which feed water a.t _te=m generator 

pressure. 

2. The inlet to the bins which directly feed tr.e Dulverized or 

stoker systems unless the bins are sized to store more than eno 

coal to operate the steam generator 72 hour*- at full load. Wher 

large bins are installed, the inlet to the c-fected facility is 

outlet of the bins feeding the pulverizer :r stoker systems. 

3. The combustion air intakes. 

The major points which define the outlets of the affected facilit y e 

1. Any steam outlet 

2. Any bottom ash outlet 

3. The outlet of the last system installed before the stack, such 

as the outlet of any induced draft fan. 

All components of the steam generator installed between these points are 

part of the affected facility except any air pollution control systems, si 

as electrostatic precipitators, mechanical collectors, baghouses, or 

scrubbers. 

Replacement of the pulverizer system with a similar system or 

replacement of component parts of the pulverizer system with similar 

parts would riet be eorisi_ere_ a modif!«_'source. However, replacement 

or redesign of the pulverizer system which would substantially change 

ML.--

ail Mi I* r,l! 

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P.12 

the ph.ys.ical characteristics of the pulverized coal may be a change 

where modification regulations apply. 

Likewise changes in the design of the combustion air system 

which change the way combustion air is introduced to the combustion 

chamber would cause a source to be evaluated to determine if 

modification regulations should apply. Changing the combustion air 

damper settings is not a modification as long as no redesign of the 

combustion air system is involved. 

The steam generation system includes the feedwater treatment 

system, watertubes, economizer, and superheat and reheat sections. 

Maintenance of these components is not a modification. Major redesign 

of these parts would cause a source to be evaluated to determine if 

modification regulations should apply. Tt is doubtful that redesign 

of the feedwater treatment system, the economizer, or the superheat 

or reheat sections would affect NO ' emissions. Redesign of the steam 

generation system components which affect combustion temperaturessuch as the waterwall sections—could change N0Y emission characteristics. 

Redesign of the draft system such as changing from induced draft 

conditions to pressurized firing conditions would cause a source to 

be evaluated to determine if modification regulations should apply. 

Changes in the fuel combustion system which, would be modifications 

are: 

a) changes in the number of burners 

b) changes in the type of burners ..___iiil,siiB-.5;.4._ 

•__^:>and_i^;_j:il_ngeV:fn':the location of burners. 

_i^__r:r_i 
I !!.!• 

•!1 

Althouah a change to a different nitrogen content or a different 

moisture content coal or a switch from lignite to non-lignite coal 

might be considered a modification, these changes are exempted from 

modification evaluation by current regulations. 

Sources, which by reason of the date of new construction, are 

subject to the NO new source performance standard for coal combustion 

A 

continue to be subject to the original standard in spite of any subsequent 

changes in solid fossil fuels or alteration. In cases where the original 

NO standard is revised to become more restrictive, none of the foregoing 

discussed modifications should cause the source regulated by the original 

NO standard to become subject to the more restrictive standard unless 

the modifications are so extensive as to be classed as reconstruction. 

(See Section 5.3). 

5.2.3 Modification of Oil- or Gas-Fired Steam Generators to Fire Coal 

The discussion of Section 5.2.3 is limited to modifications which 

would cause a source to become subject to NO new source performance 

standard modification regulations for large pulverized coal (other than 

lignite)-fired steam generators. 

Alterations which might cause an existing oil or gas-fired steam 

generator to become subject to NO modification regulations for coalA 

fired steam generators are alterations involving a switch from gas or 

oil to coal. Current regulations provide that if the oil or gas-fired 

:^source i s.~ al ready idesn' gned-to f ire^coah- --switcfr to coal^does mt^~-

cause the source to become subject to coal-fired steam generator NO 

modification regulations. In addition, Section 111(a)(8) of the Clean 

iiiO-lTre-t.i ori nrf Tons 

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!§! • 

! :! 1] 

i';G!: 

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fill;.. 

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,.( ;nn 

I'll:. 

source (see Section 5.3). 

Rulings on whether alterations of fossil fuel-fired steam generators 

constitute a modification can be obtained by contacting a Ll. S. Environmental Protection Agency Regional Office of Enforcement. 

5.3 RECONSTRUCTION 

The purpose of reconstruction regulations is to prevent the 

perpetuation of existing sources. When modifications or replacements 

become so extensive as to create an essentially new source, the source 

becomes a reconstructed source and is subject to the new source performance standards which aoply at the time of initiation of reconstruction. 

According to the provisions of Subpart A, Part 60, Subchapter C, 

Chapter 1, Title 40, Code of Federal Regulations, a facility becomes a 

reconstructed source irrespective of any change in emission rate when 

a) the fixed capital cost of the new components exceeds 50 percent 

of the fixed capital cost that would be required to construct a comparable 

entirely new facility and 

b) it is technologically and economically feasible to meet 

applicable standards. 

Rulings on whether changes to a fossil fuel-fired steam generator 

constitute reconstruction can be obtained by contacting a U. S. Environmental Protection Agency Regional Office of Enforcement. 

iai—•TPSiaW'a-'.' --V * "I' iL-^E—.-

___ • 

- •» '-•".*:^_r^'_-i'1_ 

5- « 
•Aoi^^TtC^ay^S^, ^ P$,*k_*»_MQ*< -R-s-.n-_a. Sl_^ tU.W.. %_fe 

STACK 

/rfTticWl Faolif ^ 

Some associated equipment Is omitt 

for clarity. Tor a complete listing 

of equipment, .cc IB CrR Part 101 

section MO . Jl I. 312, 314. 

GENERATING UNIT 

BOUNDARY 

u u 

SUPERII CATER 

REIIEATER 

1 " 11 • i ill " 

*• i 11 !• . 

, > )|I M * 

- m i 11 11 i i | i i | i 111 . 

ECONOMIZER 

CONTROLS 

TO 

MONITOR 

AND 

OPERATE 

//\\//\ \ //WZ^aN 

fOUNDATIONS AND STRUCTURAL STCE L 

SITE PREPARATION 

TURBIHE/GENERATOR 

GENERATOR 

ASH HANDLING 

XI